GOVERNMENT’S MOTION TO DISMISS COMPLAINT
The UNITED STATES OF AMERICA, by its attorney, ANDREW S. BOUTROS, United States Attorney for the Northern District of Illinois, respectfully moves this Court to dismiss the complaint in this matter.
Dated: November 3, 2025
                                                        
                                            FACTS SUPPORTING PROBABLE CAUSE
4. On or about October 3, 2025, at approximately 9:15 a.m., I observed Border Patrol Agents (BPAs) with United States Customs and Border Protection (CBP), Enforcement and Removal Officers (ERO) with U.S. Immigration & Customs Enforcement (ICE), Special Agents with Homeland Security Investigations, and other law enforcement clearing the road into and out of the Broadview Service Staging Area (BSSA), an ICE facility used to process individuals apprehended for being unlawfully present in the United States, and surrounding areas in Broadview, Illinois.
5. I was present on scene and observed many protestors in the area of South 25th Avenue at Harvard Street, blocking and crowding the intersection as law enforcement officers were clearing a path for the exit and entry of law enforcement vehicles onto Harvard Street, which leads to the BSSA, in the performance of their official duties.
6. I also reviewed body-worn camera footage from Border Patrol Agent A regarding various arrests made on October 3, 2025. In the video, at approximately 9:23 a.m., Border Patrol Agents encountered SHERIDAN in a grassy area near the entrance to the BSSA parking lot from Harvard Street and 25th Avenue in Broadview. In the body camera video, I observed that the Officers in contact with SHERIDAN wore vests clearly marked with the words “Police” and either “U.S. Border Patrol” and/or “HSI” on their vests.
                                                        
                                            7. At approximately the 16:04 minute marker on the body-worn camera of Border Patrol Agent A, I observed a tall Caucasian male with red hair (later identified as SHERIDAN), wearing a white helmet and a white multicolored respirator, as well as with a black shirt and black pants, standing with his hands across his body. BPAs, specifically Border Patrol Agent A, are heard in the video directing SHERIDAN to move back. In the video, at one point after Border Patrol Agent A attempts to move SHERIDAN back by nudging his elbow, SHERIDAN responds by picking his hand up and putting it back into the crossed position in a shrug manner and does not move back.
8. Based on my review of Border Patrol Agent A’s body-worn camera, Border Patrol Agent B specifically instructed SHERIDAN to move back several more times. Border Patrol Agent B and other BPAs provided verbal commands, with Border Patrol Agent B saying, “Move back or you’re under arrest.”
9. While others followed the agents’ direction, SHERIDAN is seen in the video not moving and is heard on the recording saying back, “There are people behind me, you fucking idiot.”
10. Border Patrol Agent A is then seen in the video putting his hand on the chest area of SHERIDAN in an attempt to move him back.
11. Border Patrol Agent A stated that SHERIDAN did not obey commands, appeared to lock arms with other protestors on scene, and from his peripheral vision looked like he took a swing at Border Patrol Agent B. Border Patrol Agent A further stated that he witnessed SHERIDAN push Border Patrol Agent B back when Border
                                                        
                                            Patrol Agent B attempted to push SHERIDAN back. Border Patrol Agent A stated that he further witnessed Border Patrol Agent B falling forward and assisted Border Patrol Agent B with the arrest of SHERIDAN.
12. Border Patrol Agent B stated that he recalled SHERIDAN as a protestor around 9:30 to 10:00 a.m., to whom he provided verbal commands to several times to move back as he was attempting to clear the entry and exit way into Harvard St. and South 25th Avenue., leading to the BSSA. Border Patrol Agent B stated that Law Enforcement Officers were attempting to clear a path for the safe entry and exit of law enforcement vehicles, to secure a safe environment.
13. Border Patrol Agent B stated that SHERIDAN was actively resisting verbal commands and physical attempts by law enforcement to move him back. Border Patrol Agent B stated that he then physically attempted to move SHERIDAN back with his hands. Border Patrol Agent B stated that SHERIDAN pushed him back, and that is when Border Patrol Agent B and other Law Enforcement Officers brought SHERIDAN down onto the ground and placed SHERIDAN under arrest. Border Patrol Agent B recalled that the arrest took place on a grassy area near Harvard Street and South 25th Avenue in Broadview. Border Patrol Agent B stated that SHERIDAN did not actively swing at him but pushed back and resisted him.
14. SHERIDAN is also seen in the body-worn camera footage being brought to the ground by Border Patrol Agent B, assisted by several other officers, and placed in custody.
                                                
    
    
    
    
            Good morning. Federal prosecutors have moved to dismiss another case stemming from protests outside Broadview's ICE facility — this time involving an alleged attack on U.S. Border Patrol commander Greg Bovino.
The feds recently sought extra time to indict in this case.
               
            
            
                04.11.2025 13:06 — 👍 51    🔁 24    💬 1    📌 3                      
            
         
            
        
            
            
            
            
                                                
                                                
    
    
    
    
            Explosive article: 
White House fires FHFA inspector general. (FHFA head Pulte is playing key role in Trump's vindictive prosecutions.) IG was trying to turn over "constitutionally required" info to EDVa prosecutors & letter to lawmakers saying Pulte not cooperating.
www.reuters.com/world/us/wat...
               
            
            
                04.11.2025 13:13 — 👍 58    🔁 29    💬 6    📌 1                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            words are nice, now let's see action -- plenty of video out there of lawless practices, arrest the perps. How's it going with those license plate changes? Can't make mask wearing by law enforcement illegal in Illinois?
               
            
            
                04.11.2025 13:28 — 👍 0    🔁 0    💬 0    📌 0                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            It's Day 35 of the Republican Shutdown — now tied with the shutdown of 2018-2019 as the longest in U.S. history.
               
            
            
                04.11.2025 13:16 — 👍 122    🔁 23    💬 6    📌 1                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            guess using your freedom of speech is impeding now?
               
            
            
                04.11.2025 13:20 — 👍 4    🔁 1    💬 0    📌 0                      
            
         
            
        
            
            
                            
            
            
            
    
    
    
    
            As the man called out Border Patrol Goons, they approached him and issued him a warning for “impeding” their duties.  Despite the warning, he continued his actions.
Evanston, Illinois.
               
            
            
                04.11.2025 13:16 — 👍 69    🔁 28    💬 7    📌 1                      
            
         
            
        
            
        
            
            
            
            
            
    
    
    
    
            me, too
               
            
            
                03.11.2025 19:05 — 👍 8    🔁 0    💬 0    📌 0                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            Had the same thought
               
            
            
                03.11.2025 18:30 — 👍 16    🔁 1    💬 1    📌 0                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            Is he talking about when Tr*mp comes to build another golf course?
               
            
            
                03.11.2025 18:22 — 👍 86    🔁 2    💬 4    📌 0                      
            
         
            
        
            
            
            
            
                                                
                                                
    
    
    
    
            👇👇
               
            
            
                03.11.2025 18:21 — 👍 4994    🔁 1424    💬 682    📌 182                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            "Throwing the meat sandwich at point blank range" sounds like what JD Vance does to couches.
               
            
            
                03.11.2025 18:22 — 👍 1916    🔁 277    💬 143    📌 20                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            my thought exactly -- going back to Afghanistan or what?
               
            
            
                03.11.2025 18:57 — 👍 0    🔁 0    💬 1    📌 0                      
            
         
            
        
            
            
            
            
                                                
                                            Caption: Border Patrol agents detain painter Krzysztof Klim while verifying his identification on Oct. 31, 2025, next to Halloween decorations outside a house in Chicago’s Edison Park neighborhood. Klim, originally from Poland and now a U.S. citizen, was briefly detained and then released. (Brian Cassella/Chicago Tribune)
                                                        
                                            U.S. Border Patrol agents watch the street while others question and detain a man they found painting a house in Chicago’s Edison Park neighborhood on Oct. 31, 2025, during immigration enforcement operations. (Brian Cassella/Chicago Tribune)
                                                
    
    
    
    
            The photos in this Chicago Tribune piece… It's a quiet middle-class inner suburb, but these guys look like they're in Fallujah circa 2006.
The uniforms indicate Border Patrol and its BORTAC "special operations" unit.
www.chicagotribune.com/2025/10/31/c...
               
            
            
                03.11.2025 18:31 — 👍 649    🔁 241    💬 37    📌 33                      
            
         
            
        
            
            
                            
            
            
            
    
    
    
    
            Great question!
               
            
            
                03.11.2025 18:34 — 👍 54    🔁 20    💬 4    📌 0                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            The defense should just loop video of ICE tacking, shooting, tear-gassing protesters.
               
            
            
                03.11.2025 18:34 — 👍 15    🔁 2    💬 0    📌 0                      
            
         
            
        
            
            
            
            
            
    
    
            
                            
                        
                Jury selection begins in the trial of D.C.'s 'sandwich guy'
                Sean Dunn went viral this summer for throwing a salami sub at a Customs and Border Protection agent.
            
        
    
    
            NEW: Jury selection begins in the trial of sandwich guy today. The prosecutors are accusing him of "throwing a meat sandwich" at "point-blank range." 
POINT-BLANK RANGE 💀 www.nbcnews.com/politics/tru...
               
            
            
                03.11.2025 18:05 — 👍 9422    🔁 2438    💬 1393    📌 436                      
            
         
            
        
            
            
            
            
                                                
                                            The image shows a tweet from Elizabeth Warren (@ewarren) that reads:
“The Trump administration firing nearly all of the Special Education workers at the Department of Education sends a clear message:
They don’t believe that children with disabilities deserve an equal education.
The cruelty is staggering.”
                                                
    
    
    
    
            Many red-state families with special-needs kids will be affected, too, when funding for their children’s programs gets cut off.
               
            
            
                03.11.2025 18:35 — 👍 1789    🔁 415    💬 62    📌 17                      
            
         
            
        
            
            
            
            
                                                
                                                
    
    
    
    
               
            
            
                03.11.2025 18:36 — 👍 76    🔁 40    💬 4    📌 6                      
            
         
            
        
            
        
            
            
            
            
            
    
    
    
    
            Brett Kavanaugh's behavior during today's second oral arguments has been incredibly obnoxious and rude. He is so eager to kill a service member's lawsuit against a negligent government contractor that he keeps interrupting other justices, raising his voice, and getting emotional. Weird and erratic.
               
            
            
                03.11.2025 17:22 — 👍 14817    🔁 3846    💬 1697    📌 649                      
            
         
            
        
            
            
            
            
                                                
                                            Dayanne Figueroa was on her way to get coffee before heading to work when she encountered a chaotic scene in West Town: heavily armed, masked federal agents making arrests on a residential street. 
People yelled as vehicles honked their horn — a sign now used to alert neighbors that immigration federal agents are in the area — and witnesses said federal agents had arrested several landscaper workers presumed to be in the country without authorization. 
As Figuero tried to drive through the 1600 block of West Hubbard Street on Friday, Oct. 10, an unmarked vehicle driven by federal agents collided with Figueroa’s as it tried to speed away from a hostile crowd, multiple videos reviewed by the Tribune show. 
Seconds after the crash, agents abruptly stopped their vehicle and exited with weapons in hand pointing at Figueroa, a U.S citizen. Agents then forcibly opened her door and pulled her out of the vehicle by her legs without identifying themselves, presenting a warrant or informing her that she was under arrest. As bystanders yelled, “You hit her! We have it on video!” agents ignored the crowd and forced Figueroa into a red minivan and drove away. 
Her car was left behind in the middle of the road, her coffee still in the cup holder, and her keys in plain view.
                                                
    
    
    
    
            In Chicago, a woman was driving to get coffee when a DHS vehicle fleeing an angry crowd crashed into her car. Armed agents jumped out of the vehicle, yanked her door open, pulled her by the legs out of her car at gunpoint, held her incommunicado for hours, then released her with no charges.
               
            
            
                03.11.2025 18:34 — 👍 4532    🔁 2487    💬 210    📌 234                      
            
         
            
        
            
        
            
            
            
            
            
    
    
    
    
            Today, Mike Johnson will keep the House adjourned for the 91st day out of the last 103.
12 days of work in 103 days.
With full pay and benefits.
The senate has been working, so this is not about the shutdown.
It is about avoiding a vote to release the Epstein files.
               
            
            
                03.11.2025 10:50 — 👍 21439    🔁 8287    💬 759    📌 435                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            I guess if we know which wrestling event his girlfriend is singing the national anthem at this weekend we will know where the FBI Director will be with our jet.
               
            
            
                03.11.2025 11:06 — 👍 3307    🔁 667    💬 68    📌 13                      
            
         
            
        
            
            
            
            
                                                
                                                
    
    
    
    
            Keystone Kash gets Community Noted on his pathetic attempt to deflect attention from his jet flights to his girlfriend’s music career.
               
            
            
                03.11.2025 11:12 — 👍 3225    🔁 999    💬 92    📌 29                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            So CBS is just going to be Fox Lite?
               
            
            
                03.11.2025 11:27 — 👍 9647    🔁 1843    💬 879    📌 135                      
            
         
            
        
            
            
            
            
                                                
                                                
    
    
    
    
               
            
            
                03.11.2025 11:48 — 👍 12416    🔁 3890    💬 336    📌 155                      
            
         
            
        
            
            
            
            
            
    
    
    
    
            The 400 richest Americans are now worth a record $6.6 trillion.
The entire bottom 50% of America is worth just $4.2 trillion.
Read that back.
When 400 people control more wealth than half a country’s population, we have a very serious problem.
               
            
            
                03.11.2025 01:30 — 👍 20554    🔁 7752    💬 641    📌 420                      
            
         
            
        
            
            
                            
            
            
            
    
    
    
    
            King Charles III has begun the process of stripping the royal titles from his brother, Andrew, and to evict him from his home in Windsor amid the ongoing Jeffrey Epstein scandal. President Donald Trump was asked about his thoughts on what has happened in the royal family.
               
            
            
                03.11.2025 11:53 — 👍 58    🔁 20    💬 45    📌 13                      
            
         
    
         
        
            
        
                            
                    
                    
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